Privacy Policy
This Personal Data Protection Policy (“Policy”) sets out the basis which Clearwater Communications (herein “CwC”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process Personal Data (“Data”) of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. PERSONAL DATA
Depending on how you interact with CwC and the purpose of the interaction, CwC may collect the following Data:
1.1. Data concerning your requests for information in the contact section: We process your personal data in order to respond to the requests you make via the contact form on our Website. This data includes but is not limited to your gender, your full name, your company, your e-mail address, your job title or your telephone number.
1.2. Browsing data: this Data refers to how the User browses the Website. This data may include the IP address, screen resolution, browser used, browsing time, search history, operating system used, language and pages viewed.
1.3. Cookies: this Data is used by our website to improve your browsing data, essential for the working of basic functionalities of our website and to help us analyze and understand how you use our website generally, recognize your repeat visits and preferences, as well as to measure and analyze traffic. Cookies will be stored in your browser only with your consent. By clicking “Accept” on our cookie banner, or if you continue to explore our website without changing your cookie settings, you consent to the use of the cookies on our website. You also have the option to opt-out of these cookies by changing your cookie settings anytime. However, opting out of some of the cookies may have an effect on your browsing experience.
1.4. Data on the use of social media: when you interact with social media features, these communications are governed by the personal data protection policies of the social media platforms, which we suggest you consult.
2. COLLECTION OF DATA
Depending on how you interact with CwC, we may collect your Data as described below:
2.1. CwC collects your Data from you directly when you complete a contact form or when you contact us (e.g. by sending an email).
2.2. CwC collects your Data indirectly when you browse the Site by means of cookies and tags under the conditions defined above. CwC also collects your Data through third parties whose social media you use when you use the account you hold with said third parties to log in or register for an event.
2.3. When you submit Data to CwC, it is your responsibility to ensure that it is accurate and complete. Where necessary, you must update your data.
2.4. The Data presented as mandatory is necessary to process your request and for us to provide you with the requested services. The mandatory or optional nature of the Data is indicated on the forms, together with the possible consequences in case of failure to respond.
3. DEEMED CONSENT BY NOTIFICATION
We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses 5 and 6. If CwC intends to rely on deemed consent by notification for such secondary purposes, We will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.
In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
(a) Helping us to improve the Activities, our Events, our Premises, our Sites and our Products and Services.
(b) Before relying on deemed consent by notification, CwC will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
(c) You may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
4. USE & DISCLOSURE OF DATA
We may use your Data for any of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) any other incidental business purposes related to or in connection with the above.
We may disclose your data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b) to third party service providers, agents and other organizations we have engaged to perform any of the functions with reference to the above mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of CwC or another person. In relying on the legitimate interests exception of the PDPA, CwC will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services;
c. Network analysis to prevent fraud and financial crime, and perform credit analysis; and
d. Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
5. ACCURACY, RETENTION & TRANSFER OF DATA
We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
6. WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below:
6.1. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
6.2. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 3 above.
6.3. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
7. ACCESS TO AND CORRECTION OF DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
8.PROTECTION OF DATA
CwC implements appropriate security measures to safeguard your personal data against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. We have introduced appropriate administrative, physical and technical measures such as minimized collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure etc.), encryption of data, data anonymization, up-to-date antivirus protection, regular patching of operating system and other software, secure erasure of storage media in devices before disposal, web security measures against risks, usage of One Time Password(OTP), Two Factor Authentication (2FA) and Multi-Factor Authentication (MFA) to secure access, along with security review and testing performed regularly.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
9. DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
By Email to: hello@cw-comms.com
By Post, Addressed to: Data Protection Officer
Hong Kong: 6/F Cheung Hing Industrial Building, 12P Smithfield Road, Kennedy Town, Hong Kong
Singapore: 175A Bencoolen Street, #06-06 Burlington Square (Office Tower), Singapore 189650
Any query or feedback should include, at least, your full name and contact information. We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time, indicated in Clause 6.
10. EFFECT AND CHANGES TO POLICY
10.1. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
10.2. We may revise this Policy from time to time without any prior notice, listing the date on which the Policy was last updated.
10.3. If any of the clauses in this Policy are declared void or contrary to the regulations, they will be deemed unwritten but will not invalidate the other clauses of the Policy.
10.4. You are invited to consult this Policy regularly to determine if any such revision has taken place by referring to the date on which this Policy was last updated.
10.5. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
First Published Date: 8 Mar 2025
Effective Date: 8 Mar 2025
Last Updated: 8 Mar 2025